Joseph De Felice, et al. v. Chugach Maintenance Services, Inc., et al.
Filing
94
STIPULATION and ORDER to Enlarge Time to: (1) File Response to Second Amended Complaint and (2) Make FRCP 26(a)(1) Initial Disclosures signed by Magistrate Judge Gary S. Austin on 3/2/2010. (Esteves, C)
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Mark E. Terman (CA State Bar #: 116294) markterman@reish.com Pascal Benyamini (CA State Bar #: 203883) pascalbenyamini@reish.com REISH & REICHER 11755 Wilshire Boulevard, 10th Floor Los Angeles, CA 90025-1539 Telephone Number: (310) 478-5656 Facsimile Number: (310) 478-5831 Attorneys for Defendants CHUGACH ALASKA CORPORATION, CHUGACH MANAGEMENT SERVICES, INC., MEL LYNCH, MICHAEL COWART, TOBY COWART, LORI FROST AND RICK TATE UNITED STATES DISTRICT COURT EASTERN DISTRICT OF CALIFORNIA
JOSEPH DE FELICE, ALEXI ZUNIGA, JACKIE MALCOMB, AND JAMES MAMULA Plaintiff(s), vs. CHUGACH ALASKA CORPORATION, INC., CHUGACH MANAGEMENT SERVICES, INC., MEL LYNCH, MICHAEL COWART, TOBY COWART, LORI FROST AND RICK TATE, Defendants.
CASE NO.: 1:06-cv-0048 AWI (GSA)
ORDER ON STIPULATION TO ENLARGE TIME TO: (1) FILE RESPONSE TO SECOND AMENDED COMPLAINT AND (2) MAKE FRCP 26(a)(1)INITIAL DISCLOSURES
IT IS HEREBY STIPULATED by and between Plaintiffs Alexi Zuniga, Jackie Malcomb and James Mamula (collectively "Plaintiffs"), through their attorneys of record, and Defendants Chugach Alaska Corporation, Inc. ("CAC"), Chugach Management Services, Inc. ("CMSI"), Mel Lynch, Michael Cowart, Toby Cowart, Lori Frost, and Rick Tate, through their attorneys of record, as follows: 1. The current deadline for defendants to file their response to the second amended
complaint is March 3, 2010. 2.
07858-405
Counsel for the Parties are engaged in meet and confer regarding Defendants'
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STIPULATION TO ENLARGE TIME TO: (1) FILE RESPONSE TO SECOND AMENDED COMPLAINT AND (2) MAKE FRCP 26(A)(1)INITIAL DISCLOSURES; [PROPOSED] ORDER
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intended FRCP 12(b)(6) motion to dismiss all defendants except the employer, CMSI. If such meet and confer is successful, judicial time and the Parties resources would be spared. Additional time is needed to conclude such meet and confer and to negotiate possible conditions to voluntary dismissals. 3. The Parties agree, and request that the Court order, that the time to file
responses to the second amended complaint be enlarged by 20 days, to March 23, 2010. 4. The February 22, 2010 Scheduling Order in this action requires that the initial
disclosures pursuant to FRCP 26(a)(1) be made by March 22, 2010. 5. To parallel the change in the date to file responses to the second amended
complaint, the Parties agree, and request that the Court Order, that the initial disclosures date be enlarged to April 12, 2010. 6. this action March 1, 2010 HIRST & CHANLER LLP By: /s/ Michael A. Hirst MICHAEL A. HIRST LESLIE S. GUILLON Attorneys for Plaintiffs March 1, 2010 REISH & REICHER By: /s/ Mark E. Terman MARK E. TERMAN PASCAL BENYAMINI Attorneys for Defendants ORDER IT IS SO ORDERED. Dated: March 2, 2010 /s/ Gary S. Austin HONORABLE GARY S. AUSTIN This Stipulation is made in good faith to provide for efficient management of
United States Magistrate Judge
07858-405
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STIPULATION TO ENLARGE TIME TO: (1) FILE RESPONSE TO SECOND AMENDED COMPLAINT AND (2) MAKE FRCP 26(A)(1)INITIAL DISCLOSURES; [PROPOSED] ORDER
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